Privacy Policy

At Every.io (“Every”), we take your privacy seriously.

If you visit any of Every’s websites, download, or use the Every App, or use any of Every’s related services (collectively, the “Services”), Every will ask for, collect, and store personal information about you (your “Personal Data”). We would be unable to provide our Services to you without the Personal Data you provide us, which is why we take our responsibility to protect your Personal Data very seriously. We also want to make very clear how we use your Personal Data so that you can make informed choices about your use of our Services.

This document (our “Privacy Policy”) explains how we collect and use your Personal Data, how and with whom we share your Personal Data, and how we protect your Personal Data. This Privacy Policy applies to the Every websites (the "Website"), the Every App and all related services we may provide you, and is subject to the Every Terms of Service available at https://www.every.io/termsofservice. All undefined and capitalized terms have the same meaning as the terms used in the Every Terms of Service. If you have questions about this Privacy Policy, or have suggestions for how we can improve it, please contact us at support@every.io.

If you do not want us to collect Personal Data from you or share Personal Data with any third parties or otherwise disclose your Personal Data, you should not access our Website, download or use the Every App, or use our Services.

1. Personal Data We Collect. In the table below, you will find a list of categories of Personal Data that Every collects, and some examples to help you better understand each category. We have also identified the main sources and purposes for collection:

Categories of Personal Data	Examples	Sources of Personal Data	Purposes for Personal Data Collection
Identifiers	First and last name, email address, mailing address, username, password, or other Every Account access credentials, and device fingerprint.	Consumer directly (e.g. forms you complete or services you obtain from us)	• File payroll taxes on your behalf • Keep track of the Personal Data associated with your Every Account • Help you access and restore access to your Every Account • Prevent others from accessing your Every Account • Send administrative information to you about your Every Account
Customer Records	Unique identifiers associated with your bank, including bank account names, bank routing and account numbers, social security numbers, driver’s license or other valid government photo identification, and credit report.	Consumer directly (e.g. forms you complete or services you obtain from us)	• Permit our financial partners to verify your identity to comply with anti-money laundering laws • Transfer money into Every’s bank account to pay our fees • Permit us and our financial partners to comply with applicable consumer protection laws • Provide our Services to you
Internet or other electronic network activity information	IP address, computer or mobile device unique ID number.	Consumer indirectly (e.g. from activity on our websites or the Every App)	• Analytics • Advertising and marketing • To keep our websites and the Every App safe and secure • Improve our Services

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Identifiers
Examples	First and last name, email address, mailing address, username, password, or other Every Account access credentials, and device fingerprint.
Sources of Personal Data	Consumer directly (e.g. forms you complete or services you obtain from us)
Purposes for Personal Data Collection	• File payroll taxes on your behalf • Keep track of the Personal Data associated with your Every Account • Help you access and restore access to your Every Account • Prevent others from accessing your Every Account • Send administrative information to you about your Every Account
Customer Records
Examples	Unique identifiers associated with your bank, including bank account names, bank routing and account numbers, social security numbers, driver’s license or other valid government photo identification, and credit report.
Sources of Personal Data	Consumer directly (e.g. forms you complete or services you obtain from us)
Purposes for Personal Data Collection	• Permit our financial partners to verify your identity to comply with anti-money laundering laws • Transfer money into Every’s bank account to pay our fees • Permit us and our financial partners to comply with applicable consumer protection laws • Provide our Services to you
Internet or other electronic network activity information
Examples	IP address, computer or mobile device unique ID number.
Sources of Personal Data	Consumer indirectly (e.g. from activity on our websites or the Every App)
Purposes for Personal Data Collection	• Analytics • Advertising and marketing • To keep our websites and the Every App safe and secure • Improve our Services

2. Personal Data Shared with Third Parties. Except as described in this Privacy Policy and unless you give us permission in writing, Every will never share, sell, or communicate your Personal Data to or with anyone for any reason. We only share and disclose your Personal Data with the companies listed in the table below. We have categorized each company type to help you understand why we collect your Personal Data.

Categories of third parties with whom we share your Personal Data	Why we share your Personal Data	Is Personal Data shared for a business purpose?
Every Service Providers	We may share your Personal Data with third-party vendors, consultants, contractors, and other service providers who help us provide the Services to you and who need access to such information to do the work. Specifically, we share your Personal Data with: • Unit for the purpose of providing banking services to Every and to you. For information on how Unit handles your personal data, please refer to their privacy policy available at https://www.unit.co/privacy-policy. • Zeal for the purpose of filing payroll taxes. For more information on how Zeal handles your personal data, please refer to their privacy policy available at https://www.zeal.com/privacy-policy.	Yes
Purchasers of Our Business	We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. Without your Personal Data, the company that acquires Every would not be able to continue to provide the Services to you.	Yes
Law Enforcement	We may share your Personal Data to comply, as necessary, with applicable laws and regulatory requirements, as well as legal process; respond to mandatory legal or governmental requests or demands for information; enforce our agreements, policies, procedures and Terms of Service; and protect ourselves, our customers, or the general public from illegal activities.	No

3. Cookies and Trackers. We also use cookies and other activity tracking tools to help the Every App and the Services work better. The cookies and the tools allow us to:
• Provide you Services that allow you to email or chat with our customer service team• Perform website analytics
• Improve the relevance of the advertisements you see
• Prevent fraud and prevent attacks against our Services
• Advertise additional Every products and services, and the products and services from our partner companies we think might be of interest to you

We use cookies and trackers to assign you a unique identifier so we can record:
• Websites you visit
• Length of time the advertisement was visible
• IP Address

You can block cookies at any time using your web browser settings or Every App settings, but doing so may limit your browsing experience and your ability to use certain features of the Every App. We do not currently respond to “Do Not Track” or DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

Every also uses Google Analytics. The following link explains how Google uses data when you use its partners’ websites and applications: www.google.com/policies/privacy/partners/. By using the Every Services, you are providing Every your express permission to store and access cookies and other information on your computer or phone and to use Google Analytics in connection with such activities. Please read the information at the link provided so you understand what you are agreeing to.

4. Updating Your Personal Data. While we make every effort to ensure that all Personal Data we collect and store is accurate, complete, and up-to-date, you can help us by promptly notifying us if there are any changes to your information. You will be able to view and change aspects of your Personal Data by logging in to your Every Account.

5. California Privacy Rights. If you are a California consumer, you have the right under the California Consumer Privacy Act (“CCPA”) to make the following choices regarding our use and disclosure of your Personal Data:
• Right to know. You may request, up to twice in a 12-month period, the following information about ○ the Personal Data we have collected, used, disclosed or sold about you during the past 12 months:
○ the categories and specific pieces of Personal Data we have collected about you;
○ the categories of sources from which we collected the Personal Data;
○ the business or commercial purpose for which we collected the Personal Data;
○ the categories of third parties with whom we shared the Personal Data; and
○ the categories of Personal Data about you that we disclosed for a business purpose and sold to third parties, and the categories of third parties to whom the information was disclosed or sold.
• Right to delete. You may request that we delete the Personal Data we have collected from you, subject to certain limitations under the CCPA.
• Right to opt-out from sale of Personal Data. You have the right to opt-out of the sale of your Personal Data. We do not sell your Personal Data.
• Non-discrimination. The CCPA provides that we may not discriminate against you for exercising these rights.

To submit a request to exercise any of these rights, you may contact us be emailing support@every.io or mail a letter to us at Every, Inc. 2261 Market Street #4305 San Francisco, CA 94114. We will attempt to verify your identity before responding to your request by verifying that the email address you used to send the request matches the email address that we have on file, asking you to log into your Every Account, or by requesting identifying information about you that you have provided to us in the past.

‍Consumer Request by an Authorized AgentIf any authorized agent (such as a lawyer) submits a consumer request under the CCPA on your behalf, we require the authorized agent to submit the following information so that we can confirm their authority to act on your behalf:
• Evidence of authorization to act on behalf of the California consumer: (1) California Secretary of State authorization, (2) notarized written permission from the California consumer, or (3) power of attorney.
• Evidence of identity of the California consumer: (1) first and last name, (2) email address, and (3) Every Account password.

6. How We Protect Your Privacy. We are committed to protecting the privacy and confidentiality of your Personal Data. We limit access to your Personal Data to our authorized employees, agents or subcontractors and we contractually require our business partners and service providers to limit their use of your Personal Data solely for the purposes listed in the table in Section 2. We also maintain physical, technical, and administrative safeguards to protect your Personal Data against loss, misuse, damage or modification, and unauthorized access or disclosure.

7. Retention of Personal Data. We retain Personal Data to the extent necessary to carry out the processing activities described in this Privacy Policy to comply with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies; and to protect our rights, property, or safety, and the rights, property, and safety of our employees, users and business partners.

8. Third-Party Links. The Every Website and the Every App may contain links to other websites or apps. This Privacy Policy does not apply to your access to and use of the linked websites. Your access and use of the linked websites is governed by the privacy policies of those third-party websites. We are not responsible for the Personal Data practices of such third-party websites. Please review the privacy policies of the third-party websites before you visit them or disclose your Personal Data to them.

9. Children’s Privacy. The Every Websites and the Every App are not intended for children. We do not knowingly collect, use, sell, or share any Personal Data from anyone under the age of 16. If we become aware that a child under the age of 16 has provide Personal Data to us, we will delete it.

10. Changes to this Privacy Policy; Other Policies. We may change this Privacy Policy from time to time to reflect changes about how we collect, use, and share Personal Data. The revised Privacy Policy will become effective as soon as we post it to the Every Website, or when we notify you through the Every App or through email. If you continue to use the Every Website and the Every App after we make any changes to this Privacy Policy, then it means that you accept and agree to the changes, so please check this Privacy Policy periodically for updates.

11. Contact Us. If you have any questions or concerns about this Privacy Policy, please contact us at support@every.io.

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Privacy Policy

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